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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #07-0040 ([Public Works Department Jacksonville] [Ms. Kia Trace ])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: Public Works Department Jacksonville

Individual Name: Ms. Kia Trace 

Location State: FL Country: US

View the Interpretation Document

Response text:

Mar 27, 2007


Ms. Kia Trace                  Reference No. 07-0040
Public Works Department Jacksonville
Box 5, Building 27
Naval Air Station
Jacksonville, FL 32212

Dear Ms. Trace:

This is in response to your February 6, 2007 letter, regarding the use of the proper shipping description, “Environmentally hazardous substances, (liquid or solid), n.o.s.” under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask when shipping a hazardous waste, whether the word “waste” is authorized to be used in association with this proper shipping description.

In accordance with § 172.101(c)(9), if the word “waste” is not included in the hazardous material description in Column 2 of the Hazardous Material Table, the proper shipping de for a hazardous waste (as defined in § 171.8), must include the word “waste” preceding the proper shipping name of the material, for example “Waste environmentally hazardous  (liquid or solid), n.o.s.” Additionally, Special Provision 8 authorizes a shipper to ship a hazardous substance that is not a hazardous waste under the proper shipping description “Other regulated substances, (liquid or solid), n.o.s.” Based on the information provided, Special Provision 8 does not apply to you.

Please be advised that the proper shipping description “Environmentally hazardous substance, (liquid or solid), n.o.s.” may also be used for a material not specifically listed in the § 172.101 hazardous materials table and which meets the definition of a Class 9 material. A material need not meet the definition of a hazardous substance in § 171.8 to be associated with this proper shipping description.

I hope this information is helpful. Please contact us if you require additional assistance



Charles E. Betts
Senior Transportation Specialist
Office of Hazardous Materials Standards

172.101 (c)(9)

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table